With the UK making tentative steps to follow the EU in allowing PAPs to return to pig and poultry feed. We spoke to Adrian Kesterson, Technical Advisor to the animal by-products trade association FABRA UK, about developments in the UK following Brexit.
Will the UK follow the EU in lifting the feed ban for pigs and poultry?
It’s still very early days. At the moment there is a consultation in Scotland on permitting poultry PAPs in pig feed and porcine PAPs in poultry feed. The consultation also covers the use of insect meal and ruminant gelatine in animal feed. A similar consultation is due to open in England and Wales in the near future.
If the outcome of the consultation is positive, then the government will draft the relevant legislation, but this will take time. Realistically, the rules will not change until 2026 at the earliest. The good news is that farmers and feed producers are keen to have access to the same raw materials as their counterparts in Europe. The attitude of consumers and retailers is harder to judge but UK consumers are not very different to those in Europe and there has not been a backlash in Europe since the rules changed in 2021.
Has Brexit affected the rendering sector in other ways?
Our sourcing and processing of ABPs has not changed and we still follow the same high standards as the EU under the ABP Regulations which still apply to us. UK renderers have adapted well to address the restrictions on some of our product exports caused by Brexit but there has been some impact on trade. PAP is just one example. Exports of Category 2 MBM as fertiliser are now permitted from Europe but not the UK.
Some markets for UK ABP derived products in Europe are no longer accessible because we must follow third country rules for exports to the EU. Lamb PAP is a premium petfood ingredient which we can no longer export to Europe due to restrictive export health certificate conditions since Brexit. We have found other non-EU markets for our mixed PAP products, but it takes a long time for the UK to get country specific export health certificates for our products, even where there is high demand from specific countries.
Longer-term, it is unclear if we will see greater alignment or divergence with Europe, we hear mixed messages about this which makes planning difficult.
Why is ash from incinerated Category 1 meat & bone meal permitted as fertiliser in the UK?
It’s important to stress that this difference predates Brexit by around 10 years or more. In essence, some UK renderers successfully explained to the national regulator that once Cat 1 MBM reaches the end point of incineration, the subsequent ash material should be dealt with under the Waste Framework Directive. This opens up the possibility to use the ash for fertiliser, subject to obtaining an end of waste approval for this product. Each individual company has to obtain their own end of waste approval for their product however, which is not straightforward.
In most European countries, National Authorities have taken a more conservative view and do not allow the use of Cat 1 ash for fertiliser as they still consider it to be subject to Animal By-Products Legislation. However, there is an EC instigated risk assessment taking place at the moment which may open the way for a general approval to use Cat 1 ash as fertiliser which would further enhance the sustainability credentials of the rendering sector across the EU.
What other developments are on the horizon for the UK?
As with PAP, we are still playing catch up with Europe in many regulatory areas. I was part of the EFPRA team that worked on EU’s SA BREF (Best Available Technique Reference Document) for slaughterhouses and animal by products processors. This took 4 years and concluded two years ago but we are just starting the same process in the UK. Likewise the UK emissions trading scheme replaces the EU ETS for our members
England, Wales and Scotland have also applied to WOAH to change the BSE risk status from ‘controlled’ to ‘negligible’ which will help with meat and by-product exports. We expect WOAH’s decision on this in 2025 but the benefits this could bring will not be realised immediately as various legislation will still need be revised, both in the UK and EU to allow our products such as lamb PAP to be exported to the EU.